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The ITAT quashed assessment orders for AYs 2014-15 and 2015-16 as time-barred, finding that the AO's reference to special audit under s.142(2A) was void ab initio since statutory conditions were not satisfied. Consequently, the extended time limit under s.153A was inapplicable, rendering the assessments invalid due to limitation. However, regarding additions under s.69 for unexplained payments, the Tribunal upheld the CIT(A)'s decision sustaining the AO's additions, noting the 4-year gap between alleged advance receipts and payments, and the appellant's failure to establish the source of payments from known income sources.
The ITAT quashed assessment orders for AYs 2014-15 and 2015-16 as time-barred, finding that the AO's reference to special audit under s.142(2A) was void ab initio since statutory conditions were not satisfied. Consequently, the extended time limit under s.153A was inapplicable, rendering the assessments invalid due to limitation. However, regarding additions under s.69 for unexplained payments, the Tribunal upheld the CIT(A)'s decision sustaining the AO's additions, noting the 4-year gap between alleged advance receipts and payments, and the appellant's failure to establish the source of payments from known income sources.
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